Personal data irrelevant in contact tracing
The signatures and other unnecessary personal information of those infected with the coronavirus disease (Covid-19) are irrelevant and should not be collected, according to the National Privacy Commission (NPC).
The NPC's statement came after it found out that some private establishments and government agencies involved in contact tracing were collecting such unnecessary information.
To address the issue, lawyer Stephen John Duma of the NPC Compliance and Monitoring Division asked data protection officers (DPO) to update their privacy notice, manual, and to recreate a privacy impact assessment in light of the pandemic.
“In every aspect of the data processing cycle, activities must observe the basic principles of transparency, legitimate purpose, and proportionality,” Duma said.
He said DPOs should provide a clear and accessible privacy notice to contact tracers and other data collectors on how to perform data collection, processing, storage, and disposal.
“Detailed information on the relevant personal data flows must be provided. You should have a clear way of employing these activities and show in your privacy notices that they have adequate organizational, physical, and technical capacity to protect data from collection to disposal,” Duma said.
He said a privacy notice must instruct the disclosure of the retention period and legal or technical basis for the collected data, aside from specifying the parties and authorities that will receive the information.
He noted that a DPO’s name and contact information should also be included in a privacy notice to provide further assistance to data collectors.
“The Commission is more than willing to provide businesses and agencies the required guidance in formulating policies and implementing measures that capture the privacy and protection needs of their data subjects,” Duma said.
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